From: Wargacki, Kimberly [mailto:kwargacki@metlife.com] 

Sent: Monday, July 20, 2015 10:21 PM

To: EBSA, E-ORI - EBSA

Subject: RIN 1210-AB32

To whom it may concern:

I am a leader on the Sales Compensation team supporting MetLife Premier Client Group. I have worked 

in this same department for close to 20 years. Your recent proposal prompted me to choose this topic 

for a college essay and further research the supporting documentation available on your website.

In my humble opinion, you have not even begun to scratch the surface of the research you need to do 

before proposing these changes. Many of the studies used in your research precede the latest financial 

crisis. These are outdated and do not provide enough information. Have you considered the clients 

surveyed? One survey refers to 1,000 clients. Only 1,000 of all the households in America? It’s also 

dated 2006 (Rand Corporation document) and provides no other details? What corporations did these 

financial advisors work for? What was the age of the client? (Because different generations take advice 

from their financial advisor very differently. See study by Andrus and Levaux in March 2014 published in 

Investment Advisor.) What type of investments were in the household? How long had they been clients 

of the advisor? And on and on.

While there is some risk in a commission based compensation platform, please do not take lightly the 

value of meaningful, personalized financial advice. I talk to advisors day in and day out. Do I see 

advisors try to game the system to earn more commission? Absolutely. However, my company has 

processes and procedures in place to mitigate risk, identify advisors with poor business practices and 

handle them swiftly. Most of the advisors I work with are motivated by the rewarding nature of their 

business. It’s difficult to only provide advice on investments in a retirement plan. Americans need 

holistic financial advice for their many unique family situations (2nd marriages, special needs kids, 

grandparents raising grandkids, etc.). Can you imagine how rewarding it would be to see the relief on 

your clients face after you helped them create a financial plan to care for their special needs client after 

they have passed away? The value of their financial advice is priceless for many and the number of 

advisors having a positive impact with their clients far exceed the selfishly motivated few.

While I don’t know whether or not the current regulations are sufficient, I can see you have not 

presented enough proof so demonstrate, beyond a reasonable doubt, this law should be changed. It 

would not be prudent to proceed with changes that would affect so many with only out dated and 

short-sited evidence. Your consideration of these comments is appreciated

Thank you.

Kim Wargacki

Director

Sales Compensation & Business Initiatives

Phone: (980) 949-4281

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